This morning, I submitted initial comments. Below, I posted the comments; above, I posted a screen shot of the agency’s confirmation receipt. In them, I argue that the rule is illegal, due to a number of flaws. For starters, it’s based on speculative technology, known as carbon capture and sequestration. More fundamentally, the Carbon Pollution Standard would result in an increase in greenhouse gas emissions, the very “pollutant” that is supposed to be controlled. EPA projects that CO2 captured from a power plant will be used to enhance oil drilling. But the agency failed to take into account the greenhouse gas emissions caused by the combustion of oil. According to my calculation, every kilogram of CO2 captured engenders 1.6 kilograms of CO2 from combusted oil. Of course, a regulation that worsens the supposed problem is absurd.

Every comment matters, even if you are not steeped in legal and regulatory minutiae. If you’d like to comment, go to www.regulations.gov and then type into the search box “EPA-HQ-OAR-2013-0495.” This will take you to the website where EPA stores all its supporting information about the regulation. In the top right corner of this page, there’s a blue button that says “comment now.” You can take it from there.